A UTILITY'S PERSPECTIVE ON DEVELOPING A COPPER TRADING PROGRAM WITHIN A CALIFORNIA WATERSHED

During recent NPDES permit renewal negotiations at a hydroelectric power plant located within a 303(d)-listed watershed in Central California, the East Bay Municipal Utility District (EBMUD) evaluated various alternatives for achieving compliance with final effluent limits for copper that will become effective on October 1, 2008. Because of the low priority assigned to completing a Total Maximum Daily Load (TMDL) for this water quality limited segment, combined with the need to achieve compliance with an extremely low effluent total copper limit that will apply well in advance of TMDL completion in 2011 or later, EBMUD has successfully implemented measures for reducing copper concentrations in the powerhouse effluent, evaluated alternatives for achieving compliance, and recently initiated a pollutant trading program with the objective of achieving a net reduction of copper mass within the watershed. Despite these efforts, however, compliance with future effluent limits for copper remains a challenge and there are significant policy concerns regarding the cost effectiveness of meeting these new effluent copper limits relative to the limited environmental benefits that will result. An overview of regulatory issues, policy issues, challenges, and strategies for achieving compliance with effluent copper limits at this facility are presented herein.